Compalint For Cancellation of Extrajudicial Partition Fajardo
Compalint For Cancellation of Extrajudicial Partition Fajardo
Plaintiffs,
Defendants
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COMPLAINT
THE PARTIES
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1
Attached and marked as Annex A is a copy of Certificate of Marriage of Reynaldo Robles
Fajardo Sr. and Laura Adriano Fajardo.
2
Attached and marked as Annex B is a copy of Certificate of Live Birth of Manuelito Adriano
Fajardo.
3
Attached and marked as Annex C is a copy of Certificate of Live Birth of Jose Milanio
Nonilo Adriano Fajardo.
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Attached and marked as Annex D is a copy of Certificate of Live Birth of Roberto Adriano
Fajardo.
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5) Plaintiff Reynaldo Adriano Fajardo, Jr. (Junior for brevity) is of
legal age, single, with residence address at 185 Purok Timog,
Caridad Village, Barangay Caridad, Cabanatuan Nueva Ecija. Said
plaintiff is one of the heirs of the late Reynaldo Robles Fajardo, Sr. 5;
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Fajardo, however he is also known to be using the name Reynaldo
Pablo Fajardo, Jr. in all his personal effects, with the Joint Affidavit
of Two Disinterested Person that Reynaldo Pablo Pajardo, Jr. and
Reynaldo Pablo Fajardo, Jr. is one and the same person. 12;
13) Plaintiff Laura Adriano Fajardo and the late Reynaldo Robles
Fajardo, Sr were married on July 14, 1943 at Immaculate
Concepcion Parish, Malolos, Bulacan. Born within this wedlock
were plaintiffs, Manuelito Adriano Fajardo, Jose Milanio Nonilo
Adriano Fajardo, Zenaida Adriano Fajardo, Roberto Adriano
Fajardo, Reynaldo Adriano Fajardo, Jr., Virgilio Adriano Fajardo
and Ma. Levita Adriano Fajardo-Esteves.
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Attached and marked as Annex H is a copy of Special Power of Attorney authorizing
plaintiff Ma. Levita Adriano Fajardo Esteves to represent Plaintiffs Laura Adriano Fajardo,
Manuelito Adriano Fajardo, Jose Milanio Nonilo Adriano Fajardo, Zenaida Adriano
Fajado, Roberto Adriano Fajardo, Reynaldo Adriano Fajardo, Jr., Virgilio Adriano
Fajardo in this present petition.
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Attached and marked as Annex I is a copy of Voter Certification of Angelita Santos Pablo.
10
Attached and marked as Annex J is the Joint Affidavit of Two Disinterested Person
attesting to the fact that Angelita Santos Pablo and Angelita Pablo Fajardo is one and the same
person.
11
Attached and marked as Annex K is the Certificate of Live Birth of Reynaldo Pablo Pajardo,
Jr.
12
Attached and marked as Annex L is the Joint Affidavit of Two Disinterested Person that
Reynaldo Pablo Pajardo, Jr. and Reynaldo Pablo Fajardo, Jr. is one and the same person.
The family live together in Bulacan, until sometime in 1955 for fear
of his life and that of his family being a hunted member of
HUKBALAHAP said late Reynaldo Robles Fajardo, Sr. decided to left
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his wife and children to his relatives in Nueva Ecija to leave for
Sablayan, Occidental Mindoro.
16) Plaintiff Laura Adriano Fajardo and the late Reynaldo Robles
Fajardo, Sr. never saw each other until the latters death on July
31, 1997. 18; Neverthelss, neither of the two moved to severe their
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13
Attached and marked as Annex M, M-1, M-2, M-3, M-4, is the copy of TCT No. T-15251
in the name of Reynaldo Fajardo.
14
Attached and marked as Annex N, N-1, N-2, N-3, N-4 is the copy of TCT No. T-15251 in
the name of Reynaldo Fajardo.
15
Attached and marked as Annex O, O-1, O-2, O-3, O-4 is the copy of TCT No. T-20053 in
the name of Reynaldo Fajardo.
16
Attached and marked as Annex P, P-1, P-2, P-3, P-4 is the copy of TCT No. T-20054 in the
name of Reynaldo Fajardo.
17
Attached and marked as Annex Q, Q-1, Q-2, Q-3, Q-4 is the copy of TCT No. T-15350 in
the name of Reynaldo R. Fajardo.
18
Attached and marked as Annex R is the copy of Certificate of Death of Reynaldo Robles
Fajardo, Sr.
marriage bonds. The Death Certificate of Reynaldo Robles Fajardo,
Sr. shows that his civil status is married at the time of his death. 19
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17) It was sometime in September 2017, that the plaintiffs found
out that the defendant Angelita Santos Pablo a.k.a Angelita Pablo
Fajardo, defendant Reynaldo Pablo Pajardo, Jr. a.k.a Reynaldo
Pablo Fajardo, Jr., defendant Reynante Pablo Fajardo and
defendant Renalyn Pablo Fajardo claiming themselves as the sole
legitimate and surviving heirs of the late Reynaldo Robles Fajardo,
Sr. have executed an ETRAJUDICIAL PARTITION OF THE ESTATE
OF LATE REYNALDO ROBLES FAJARDO, SR. WITH WAIVER OF
RIGHTS dated August 1, 2013 and adjudicated onto themselves
EQUALLY the aforedescribed parcels of land. In the same
instrument, defendants Angelita Santos Pablo a.k.a Angelita Pablo
Fajardo, defendant Reynante Pablo Fajardo and defendant Renalyn
Pablo Fajardo CEDED, TRANSFERRED and CONVEYED by way of
RELINQUISHMENT all their RIGHTS, INTERESTS AND
PARTICIPATION, over the same parcels of land to defendant
Reynaldo Pablo Pajardo, Jr. a.k.a Reynaldo Pablo Fajardo, Jr. 20
18) These factual events fraudulently deprived the plaintiffs of their
rightful shares in the properties left by their deceased parent to
which they lawfully and legally entitled to as legal heirs.
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